Cisco Supplier Ethics Policy

Policy Cisco public

Cisco Systems, Inc. and its affiliates (Cisco) are committed to the highest standards of product quality and business integrity. Cisco requires all of its suppliers and employees to conduct themselves with the highest standards of honesty, fairness, and integrity, complying with all applicable laws and avoiding even the appearance of impropriety. Supplier shall ensure that its employees, subcontractors, agents, and third parties assigned to provide services or products to Cisco act consistently with this Supplier Ethics Policy. Cisco may audit Supplier and inspect Supplier’s facilities to confirm compliance with this Policy. Cisco may require Supplier to immediately remove any Supplier employee or representative that acts inconsistently with this or any other Cisco policy. Failure to adhere to this Policy will result in disqualification from consideration for future business with Cisco and may result in termination of existing business. Supplier may contact Cisco’s Ethics Office at [email protected] for questions relating to its obligations under this Policy.

Compliance with applicable law and Cisco policies Supplier shall comply with all laws, regulations, and policies applicable to it and its dealings with Cisco, including employment laws prohibiting discrimination and harassment. If this Policy or any other applicable Cisco policy conflicts with applicable law, applicable law will govern such conflict to the extent it is impossible for Supplier to comply with both the law and the policy. If this Policy conflicts with any other applicable Cisco policy, this Policy will govern to the extent it is impossible for Supplier to comply with both policies.

Insider trading Federal and state laws prohibit trading in securities by anyone with material information not available to the public. Supplier’s interactions with Cisco may result in Supplier having access to material, nonpublic information about Cisco or another company (including Cisco’s customers, suppliers, and other business partners). Supplier shall not engage in any action to take advantage of that information, including buying or selling Cisco’s or that company’s securities or sharing that information with others.

Contents Gifts, travel, and entertainment Supplier shall not directly or indirectly provide any gift, travel, entertainment, political contribution, or Compliance with applicable law and charitable donation of any value to a Cisco employee or any third party on behalf of Cisco. Supplier Cisco policies may offer a Cisco employee a gift, travel, or entertainment only if it is: (a) appropriate (no cash or cash equivalents or other excluded gift type), does not create an actual impropriety or a perception of Insider trading impropriety, and complies with all laws, regulations, and policies for all parties), (b) of reasonable value, and (c) with full transparency of its value. Gifts, travel, and entertainment

Conflicts of interest Conflicts of interest A conflict of interest arises when a Cisco employee’s personal interest interferes with the best Unfair business practices interests of Cisco. It may occur when an employee or a family member or friend receives a personal benefit as a result of the employee’s position with Cisco. Supplier shall disclose to the Cisco Ethics Office ([email protected]) all relationships that have a potential to create a conflict of interest or the Anti-corruption appearance of a conflict of interest. Supplier shall correct any actual or perceived conflict of interest as directed by Cisco. Unauthorized lobbying on Cisco’s behalf and speaking to the press Unfair business practices Intellectual property rights, privacy, and Cisco is committed to competing fairly and in compliance with the antitrust and competition laws data protection in every country where it does business. Supplier shall comply with all applicable fair business, advertising, and antitrust competition laws; Supplier shall not fix prices, rig bids, allocate customers or Cisco’s global human rights policy markets, or exchange current, recent, or future pricing information with Supplier’s competitors.

Supplier code of conduct Anti-corruption Notice of ethical concerns Cisco is committed to doing business with integrity and in compliance with the highest anti-corruption standards. Corruption violates the public’s trust, threatens economic and social development, and hurts fair trade. Supplier shall comply with the U.S. Foreign Corrupt Practices Act, all similar anti- corruption and bribery laws in other countries, and Cisco’s Global Anti-Corruption Policy. Supplier shall not engage or attempt to engage in bribery, extortion, or embezzlement. Supplier shall conduct itself with honesty, fairness, and high ethical standards, avoiding even the appearance of impropriety in all its business interactions worldwide.

Contents Unauthorized lobbying on Cisco’s behalf and speaking to Compliance with applicable law and the press Cisco policies Supplier shall not undertake any type of lobbying or other similar representative efforts on Cisco’s behalf before any kind of government entity, official, body, or representative without the express written Insider trading consent of Cisco’s Government Affairs Group. Suppliers shall make no statements to the press about or on behalf of Cisco unless expressly authorized to do so by Cisco. Gifts, travel, and entertainment Intellectual property rights, privacy, and data protection Conflicts of interest Supplier shall comply with all applicable intellectual property rights and laws. Supplier shall only use information technology and software that it has acquired or licensed legitimately and shall use Unfair business practices them only in accordance with the terms of such licenses. Supplier shall not transfer any of Cisco’s technology, proprietary information, or trade secrets without prior written consent from Cisco’s Legal Anti-corruption Department. Supplier shall respect the reasonable privacy and confidentiality expectations of everyone with whom it does business and shall appropriately protect all data that may come into its possession Unauthorized lobbying on Cisco’s behalf because of its relationship with Cisco, including data relating to Cisco and Cisco’s employees, and speaking to the press customers, and partners. Supplier shall comply with Cisco’s instructions and with applicable privacy, data protection, and security laws and regulations when personal, confidential, proprietary, or other Intellectual property rights, privacy, and sensitive information is collected, stored, processed, transmitted, or shared. Supplier shall use data protection Cisco-provided information technology and systems only for business-related purposes authorized by Cisco. Cisco’s global human rights policy Cisco’s global human rights policy Supplier code of conduct Cisco’s Global Human Rights Policy formalizes our long-standing commitment to human rights for all people. Cisco upholds and respects human rights as contained in the United Nations Universal Notice of ethical concerns Declaration of Human Rights, the eight Core Labor Conventions developed by the International Labour Organization, the UN Global Compact, and the UN Guiding Principles on Business and Human Rights. Supplier shall conduct business in accordance with all such principles and in compliance with all applicable global and local human rights laws. Additionally, Supplier shall:

• Follow responsible business practices that do not infringe on human rights; • Regularly assess human rights risks;

• Mitigate risks and enable the remediation of adverse human rights impacts Supplier causes or to which Contents Supplier contributes; Compliance with applicable law and • Engage openly with stakeholders on issues that impact human rights; and Cisco policies • Support Cisco’s efforts to meet its human rights commitments. Insider trading Supplier code of conduct Gifts, travel, and entertainment As a founding member of the Responsible Business Alliance (RBA), formerly known as the Electronic Industry Citizenship Coalition, Cisco has adopted the RBA Code of Conduct as Cisco’s Supplier Code of Conduct. The RBA Code of Conduct reflects the basic tenets of responsible sourcing Conflicts of interest and manufacturing agreed upon by the electronics industry, including provisions for responsible management in labor, health and safety, environment, and ethics. It is an evolving document that Unfair business practices incorporates the feedback of Cisco, its peers, suppliers, customers, and outside stakeholders. Supplier shall operate in accordance with the RBA Code of Conduct, as modified from time to time. Anti-corruption

Unauthorized lobbying on Cisco’s behalf Notice of ethical concerns and speaking to the press Cisco expects all employees, customers, partners, suppliers, shareholders, and stakeholders to speak up promptly about any conduct or circumstances they believe may constitute a violation of this Intellectual property rights, privacy, and Supplier Ethics Policy or any other Cisco policy. Supplier shall promptly notify the Cisco Ethics Office at data protection [email protected] or via the Cisco EthicsLine reporting tool regarding any known or suspected illegal or improper behavior relating to dealings with or on behalf of Cisco, including behavior by Cisco’s employees or agents. Cisco’s global human rights policy

Supplier code of conduct

Notice of ethical concerns

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